Financial Aid Code of Conduct

American Sentinel University participates in the William D. Ford Federal Direct Loan Program, which includes the Direct Subsidized and Direct Unsubsidized Student Loans, the Direct Graduate PLUS Loans and the Direct Parent PLUS Loans.

To comply with the 2008 Higher Education Opportunity Act, American Sentinel adopts the following code of conduct to provide guidance to university employees, assure the integrity of the student aid process and uphold ethical conduct of university employees with regard to student loan practices. This code of conduct is applicable to all university employees and agents, the university’s Financial Aid Office and the Office of Student Accounts.

Revenue Sharing

A revenue-sharing arrangement is an agreement between an institution and a lender in which:

A lender provides or issues a loan that is made, insured or guaranteed under the Higher Education Opportunity Act to students attending the institution or to the families of such students.

The institution recommends the lender or the loan products of the lender and in exchange, the lender pays a fee or provides other material benefits to the institution (or an officer or employee), including revenue or profit sharing.

American Sentinel and its employees will not enter into any type of revenue-sharing arrangement with any lender, guarantor or servicer. All loans are processed without regard to lender or mode of transmission (i.e., electronic or paper). The university will neither recommend a private loan lender nor accept material benefits including revenue or profit sharing to the university, an officer or an employee of the university or an agent.

Gifts

Employees of the Office of Financial Aid and the Office of Student Accounts are prohibited from soliciting or accepting any gift from a lender, guarantor or servicer of education loans.

Gifts include any gratuity, favor, discount, entertainment, hospitality, loan or other similar item that has a monetary value of more than a de minimus amount. This includes gifts of services, transportation, lodging or meals, whether provided in kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has incurred. However, gifts do not include those specific exemption set forth in the Education Opportunity Act (20 U.S.C. Section 1094(e)(2)(B)(ii)).

Gifts to family members of a university employee are considered to be a gift to the employee if the gift is given with the knowledge and acquiescence of the employee and there is reason to believe the gift was given because of that employee’s position at the university.

Contracting Arrangements

Employees of the Office of Financial Aid and Office of Student Accounts shall not accept from any lender, or affiliate of any lender, any fee, payment or other financial benefit (including opportunity to purchase stock) as compensation for any consulting arrangement or other contract to provide services to a lender, or on behalf of a lender, relating to education loans.

Preferred Lender Status

American Sentinel University participates in the William D. Ford Federal Direct Loan Program, which provides student and parent loans through the United States Department of Education. Lenders in the private student loan industry will not be given a preferred status. The university will not produce a preferred lender list that gives any lender an advantage in securing business from university students. Any university-preferred lender list will clearly and fully disclose the criteria and process used by the university to select preferred lenders. Further, students will be told that they have the right and ability to select the lender of their choice regardless of the preferred lender list.

Interaction with Borrowers

American Sentinel University will not assign a borrower’s private student loan to a particular lender; all decisions will be made by the borrower in his/her independent review of borrower benefits and lender services. Further, American Sentinel will not refuse to certify or delay certification of any loan based on the borrower’s selection of a particular lender or guaranty agency.

Opportunity Pool Loan

American Sentinel University will not request or accept from any lender any offer of funds to be used for private education loans (defined in section 140 of the Truth in Lending Act) including funds for an opportunity pool loan in exchange for University providing concessions or promises regarding providing the lender with a specified number of loans made, insured or guaranteed; a specified loan volume of such loans; or a preferred lender arrangement for such loans.

Staffing Assistance

American Sentinel University will not request or accept from any lender, guarantor or servicer of student loans any assistance with call center staffing or financial aid office staffing. The university also prohibits employees, representatives or agents of any lender, guarantor or servicer of student’s loans from identifying themselves to students or their parents as employees, representatives or agents of the university.

Advisory Board Compensation

Employees of the Office of Financial Aid and Office of Student Accounts who serve on an advisory board, commission or group established by a lender, guarantor or group of lenders or guarantors, are prohibited from receiving anything of value from the lender, guarantor or group of lenders or guarantors, except that the employee may be reimbursed for reasonable expenses incurred in serving on such advisory board, commission or group. Any employee who serves on such an advisory board, commission or group shall disqualify himself or herself from any discussions about the university’s financial aid operations.

Employees of the Office of Financial Aid and the Office of Student Accounts shall comply with all other applicable federal, state and local laws and regulations, accrediting bodies, and university policies and procedures, including its Conflict of Interest Policy.